UNITED STATES ARMY FORCES COMMAND
CROSS - COMPONENT FUNDING PRIMER
JUNE 1996
DEPARTMENT OF THE ARMY
HEADQUARTERS, UNITED STATES ARMY FORCES COMMAND FORT MCPHERSON, GEORGIA 30330-6000
JUNE 1996
The structure and responsibilities of the Active and Reserve Components have changed dramatically in the past several years. The Reserve Components have become an even more vital player in America’s Army. As a result of these changes, a number of funding issues have surfaced regarding support provided between Active and Reserve Components. These issues have caused concern to many of us. My staff created this primer as a guide for all who become involved in these issues. It is a guide in the sense that it discusses the issues, provides potential solutions to them, and identifies governing publications. It is an information document only; it does not provide procedural guidance. I consider this to be a notably valuable document and I am very pleased to be able to provide it for your use. I hope that it will benefit all who use it. The Army Deputy General Counsel (Ethics and Fiscal), the Office of the Chief, Army Reserve (OCAR), the National Guard Bureau (NGB), the U.S. Army Reserve Command (USARC), and other members of the FORSCOM staff provided assistance. I thank them for their help. For questions or comments, please contact Mr. Richard Shaffer, DSN 367-6250.
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INDEX PAGE SECTION I SECTION II - CROSS-COMPONENT FUNDING (C-C F) ISSUE - BACKGROUND 3 4 5 7
SECTION III - DISCUSSION SECTION IV - APPROPRIATIONS IN CROSSCOMPONENT FUNDING AND FUNDING FLOW - REIMBURSABLE GUIDELINES AND PROCEDURES - REPROGRAMMING
SECTION V SECTION VI
10 12 13
SECTION VII - APPROPRIATIONS INVOLVED IN CROSS-COMPONENT FUNDING ISSUES SECTION VIII- EXAMPLES APPENDIX A APPENDIX B - REFERENCES - DEFINITIONS
15 27 29
I -
CROSS-COMPONENT FUNDING (C-C F) ISSUE
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EACH COMPONENT FUNDED FOR OWN MISSIONS HOWEVER, WHEN USAR
ARNG
USAR AC REQUESTS SUPPORT OF OTHERS ARNG
F NO C-C
NO C-CF PROBLEM: •PROVIDER CAN FUND SUPPORT •PROVIDER RECEIVES ADDITIONAL FUNDS FROM HIGHER HQ ------------------------------------------------------C-CF PROBLEM: •PROVIDER CANNOT FUND SUPPORT •ADDITIONAL FUNDS NOT AVAILABLE
M PROBLE
AC AC
NA TI ON A AR L G NG UA RD
AC
ACTIVE ARMY •PROVIDER REIMBURSED FOR O&M •REPROGRAM IN PROGRAM/ BUDGET CYCLE
C-C F P ROBLE M
VE ER SE R RE Y M AR AR AR US
SOLUTION
THE ISSUE:
Active and Reserve Components (both Army Reserve and Army National Guard) are funded for those missions for which they have responsibility. The Cross-Component Funding issue occurs when one component requests support from another component, and the component providing the support has not programmed nor budgeted for that support. This normally occurs during the execution or budget year, when the funding levels have already been established, and requests for unprogrammed support cannot normally be provided without additional funding. In these cases, the requesting component must provide funding for that support until funding can be realigned to the service supplier in the out-years. Until this reprogramming can occur, there may be confusion on who is responsible for providing support and how that support should be paid. This primer addresses this issue and potential solutions.
II -
BACKGROUND:
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Over the past few years, many changes have occurred which have impacted the structure and funding of the Active and Reserve Components. The Congressional budget cuts, BRAC realignments, force restructuring, downsizing in both the private and public sectors (including the military forces), and pressures of changes on the international and domestic scenes, have led to numerous initiatives to shift support responsibilities from Active to Reserve Components, and to eliminate duplication between components on services provided. The Reserve Components have become a more significant player in providing essential support to America’s Army. This has resulted in confusion on who is responsible for providing support and how that support should be paid. Previously, Active Components and Active Component funded installations were responsible for providing support to themselves, and limited support to the Army Reserve and the Army National Guard. The Active Component installations received Operation and Maintenance, Army (OMA) funding to provide that support, and most support was common-service nonreimbursable, meaning that customers were provided support at no charge to them. It was the Active Component’s responsibility to budget for, fund, and provide the services. Although the Army Reserve and the Army National Guard received support from the Active Component, they still provided and funded much support for themselves. This has gotten more complicated over the years, especially with the Tri-Component Funding concept where multiple appropriations (OMA, OMAR, and OMNG) are now funding one organization, which was previously funded by one appropriation. This is different from the Cross-Component Funding concept where the service supplier is reimbursed by the customer for services provided.
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III -
DISCUSSION:
As the Active Component structure has declined, the Reserve Components have picked up more responsibilities, including providing additional support for themselves. The Cross-Component Funding issue keeps surfacing because of the changing support responsibilities and lead time required to reprogram funds from one appropriation to another and to realign funding to match support responsibilities. Until reprogramming can be accomplished in out-years, Army Components must reimburse among themselves, using reimbursable procedures.
HOW TO FUND?
EXEC/BUD YR REIMB BUD/PROG YR REPROG
O&M APPNS
REQ
PERF
REQ
PERF
----------------------------------------------------------------REIMB \1 REQ PERF REQ REPROG PERF
P&A (PAY) APPNS
\1 REIMBURSABLE TRANSACTIONS FOR P&A FUNDS CAN ONLY BE INITIATED BY THE FUND MANAGERS. FOR EXAMPLE, MILITARY PERSONNEL ARMY (MPA) IS CENTRALLY MANAGED BY HQDA (THE ARMY BUDGET OFFICE)(ABO), AND ONLY THEY CAN ISSUE A MPA FUNDED MIPR OR CAN ACCEPT A MIPR INTO MPA. OTHER P&A APPROPRIATIONS ARE A COMBINATION OF FUNDS THAT ARE CENTRALLY MANAGED AND THOSE THAT ARE NOT.
REQ = REQUESTOR (RECEIVER)
PERF = PERFORMER (SUPPLIER)
All requirements for program years can be funded in the POM process. The Cross-Component Funding issues occur when during the year of execution or budget, one component (REQUESTOR/RECEIVER) may ask for the support of another component (PERFORMER/SUPPLIER), i.e., NG asks USAR or AC, USAR asks NG or AC, AC asks USAR or NG. There is insufficient lead time for the supporting component to program or budget for the support provided. If funds are available, the requesting component may MIPR funds to the supporting component as illustrated above, and the issue is resolved. If funds are not available, the support provider cannot
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be reimbursed. The preceding illustration shows reimbursement between the O&M appropriations and between the pay appropriations. For some time it has been the prevailing view that there were Congressional constraints on the pay and allowance appropriations in regard to the reimbursement process, and these constraints prevented reimbursement between the pay appropriations. Per 29 Apr 96 Army Deputy General Counsel memorandum, such reimbursements are allowed by the “Economy Act”, 31 USC 1535. The memorandum is referenced in Appendix A and discussed in Appendix B. As indicated on the preceding illustration, reimbursement transactions for P&A funds can only be initiated by the fund managers. MPA is centrally managed by ABO, and only they can initiate MPA reimbursement transactions. Other P&A funds are a combination of funds that are centrally managed and those that are not; therefore, levels of authority to initiate reimbursement transactions may vary. It is very important to remember that reimbursement transactions can be made only by those who have the authority to do so. If, during the execution year, the requestor of the support does not have funds available to reimburse the supplier of the support, the available options are: - The component requested to provide the support could agree and support within current funding levels, or request additional funding from higher headquarters. - If not resolved, the requesting component could submit a request to DOD to transfer funds from one component to the other within the Secretary of Defense’s Congressional annually approved total threshold. The current threshold level is $2.4 billion. It previously excluded Reserve Component appropriations.
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IV -
APPROPRIATIONS IN CROSS-COMPONENT FUNDING AND FUNDING FLOW
APPROPRIATIONS
ACTIVE COMPONENT
ARMY RESERVE
MILITARY PERSONNEL, ARMY (MPA) OPERATION & MAINTERANCE, ARMY (OMA)
RESERVE PERSONNEL, ARMY (RPA) OPERATION & MAINTENANCE, ARMY RESERVE (OMAR)
NATIONAL GUARD
NATIONAL GUARD PERSONNEL, ARMY (NGPA) OPERATION & MAINTENEANCE, ARMY NATIONAL GUARD (OMNG)
OPERATION AND MAINTENANCE FUNDING FLOW OSD
OMA OMAR OMNG OMA OMAR OMNG
CONGRESS
ABO
OMNG
OMAR
OMAR OMA OMNG OMAR
OCAR
NGB
FORSCOM
OMA OMAR OMNG OMA OMAR OMNG
OMNG
USARC
OMAR OMAR
STATES
CONUSA
INSTALLATIONS
REGIONAL SPT CMD (RSC)
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PAY & ALLOWANCE FUNDING FLOW
MPA RPA NGPA
CONGRESS
MPA RPA NGPA
OSD
NGPA
RPA
ABO
OCAR
RPA
(NOT OPEN ALLOTMENT)
NGB
(NOT OPEN ALLOTMENT)
NGPA
USARC
RPA
STATES
RSC
FUNDING FLOW:
The Active Component has the Operation and Maintenance, Army (OMA) and the Military Personnel, Army (MPA) appropriations. The Army Budget Office (ABO) centrally manages the MPA appropriation at headquarters, and distributes OMA funds to major commands (i.e., FORSCOM) via Fund Authorization Documents (FADs), which are further issued to installations via FADs. The Army Reserve component has the Operation and Maintenance, Army Reserve (OMAR) and Reserve Personnel, Army (RPA) appropriations. The Office of the Chief, Army Reserve (OCAR) distributes OMAR and RPA to major commands and to the Army Reserve Command (USARC) via the FAD process. The USARC issues OMAR to installations and OMAR/RPA to Reserve Support Commands via FADs. The Army National Guard has the Operation and Maintenance, Army National Guard (OMNG) and National Guard Personnel, Army (NGPA) appropriations. The National Guard Bureau distributes OMNG funds to the States and Major Commands (MACOMS), and distributes NGPA funds to the States. See
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charts above. For further information on uses of each appropriation, see DFAS-IN Manual 37-100-XX.
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V - REIMBURSABLE GUIDELINES AND PROCEDURES:
Generally, Army installation host/service suppliers shall fund all O&M support services required to support the host’s/supplier’s mission, and all customers (on post and off post) will be provided service at no cost. Examples are guards on the front gate of an installation and firemen for fire protection. Installation suppliers will require O&M reimbursement for all levels of support that are customer/tenant unique such as additional security guards required in a hospital. The reimbursement will be the amount of increased cost to the installation to provide the unique service. Installations may reduce the level of O&M common support services performed because of funding reductions in their base support budget. However, any O&M adjustment in levels of services must be consistent and equitable to all customers, including tenants and off-post customers. Additional guidance is available in HQDA memorandum, subject: Army Reimbursable Policy, 19 May 95 and DOD Instruction 4000.19, Inter-service & Intra-governmental Support, 9 Aug 95.
REIMBURSABLE PROCEDURES:
Reimbursable procedures will be used to reimburse service suppliers for services rendered. For example, a Military Interdepartmental Purchase Request (MIPR) is used to request O&M reimbursable services and to obligate the customers’ O&M funds. The service supplier uses the MIPR as authority to perform the services and to increase O&M funds available based on the acceptance of the customers’ order. The customers are billed at least quarterly for the O&M support provided. Additional guidance is available in DFAS-IN Regulation 37-1.
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REIMBURSEMENT PROCEDURES MIPR PROCESS
REQUESTER Direct Funds MIPR Prepared & Sent PERFORMER Reimbursable Funds MIPR Accepted Provide Support Reimbursement Reimb Funds - - - - Order Order Obligate Accrue- - - - - - - - Disburse Disburse/ Reconcile Collection Collect 1080 Billing Earning Earning
Obligate
Accrue
REIMBURSEMENT CRITERIA:
1. There must be an agreement between the requestor/receiver of support and the performer/supplier. Both must agree on the support to be provided and the dollar amount to be reimbursed. 2. The support must be a bona fide need of the current fiscal year. 3. Funds are provided by the receiver as reimbursable or direct fund cite via a MIPR, letter or message to the support supplier. Support supplier decides the method of financing and how the order will be accepted. 4. Funds cannot be provided to supplement another appropriation. 5. Funds cannot be used on items for which the funds were not appropriated or authorized. 6. Funds cannot be used to continue the availability of an appropriation beyond the normal statutory limits.
VI -
REPROGRAMMING:
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Reprogramming between appropriations in the year of execution requires specific notification of Congress. Under normal circumstances, appropriation reprogramming requests are submitted as part of the budget submission to higher headquarters. If approved, funds are reprogrammed during the PPBES cycle, and funds are moved to the appropriation required to fund the component responsible for providing the support. Lead time for reprogramming actions is 2-3 years. However, you cannot reprogram funds unless they are used for higher priority items than were originally appropriated, due to unforeseen circumstances, and in no case can they be used to provide support that has been previously denied by Congress. Additional guidance can be found in the Office of the Assistant Secretary of the Army (Financial Management & Comptroller) Reprograming Directive. As previously stated, the “Economy Act,” 31 USC 1535, allows reimbursements between the appropriations discussed herein. There are also other special circumstances, specifically identified by Congress, whereby the NGPA and RPA appropriations can be reimbursed. They are as follows: MPA can be reimbursed by the Defense Business Operations Fund (DBOF) for costs of military personnel working in the DBOF activity. For NGPA, a Funded Reimbursement Authority (FRA) program is available whereby NGPA can be reimbursed by another appropriation if approved. This FRA must be negotiated with the Office of the Chief, National Guard Bureau (OCNGB), an MOA completed, and the FRA approved by OSD. NGPA and RPA may also be reimbursed by Operation and Maintenance Appropriations for Army Reserve and National guard members who provide intelligence support to Unified Commands, Defense Agencies and Joint Intelligence Activities. For RPA, an FRA program is available whereby RPA can be reimbursed by another appropriation, if approved. This FRA must be negotiated with the Office of the Chief, Army Reserve (OCAR), a Memorandum of Agreement (MOA) completed, and the FRA issued on the funding document.
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VII - APPROPRIATIONS INVOLVED IN CROSSCOMPONENT FUNDING ISSUES: O&M Appropriations
OPERATION AND MAINTENANCE, ARMY (OMA - 21*2020 Appropriation). Funds Active Component missions and operation of Active Component installations. Funds civilian pay, travel, transportation, contracts, training, purchase of supplies and equipment, and other mission-related items. See DFAS-IN Manual 37-100-XX for further details. OPERATION AND MAINTENANCE, ARMY RESERVE (OMAR - 21*2080 Appropriation). Funds Army Reserve missions and operation of Army Reserve installations, Army Reserve centers, Regional Training Sites, Area Maintenance Support Activities, equipment concentration sites, and aviation support facilities. Funds civilian pay (including military technicians), travel, transportation, contracts, training, purchase of supplies and equipment, and other mission-related items. See DFAS-IN Manual 37-100-XX for further details. OPERATION AND MAINTENANCE, ARMY NATIONAL GUARD (OMNG- 21*2065 Appropriation). Funds Army National Guard missions and operation of National Guard camps and training sites. Funds civilian pay (including civilian technicians), travel, transportation, contracts, training, purchase of supplies and equipment, and other mission-related items. See DFAS-IN Manual 37-100-XX for further details.
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APPROPRIATIONS INVOLVED IN CROSS-COMPONENT FUNDING ISSUES: (Continued) Pay Appropriations
MILITARY PERSONNEL, ARMY. (MPA - 21*2010 Appropriation). Funds pay and allowances of Active Component personnel. Includes PCS moves and other mission-related costs. See DFAS-IN Manual 37-100-XX for further details. RESERVE PERSONNEL, ARMY (RPA - 21*2070 Appropriation). Funds pay and allowances of Army Reserve Component personnel. Includes clothing, subsistence, and other mission-related costs. See DFAS-IN Manual 37-100XX for further details. NATIONAL GUARD PERSONNEL, ARMY (NGPA - 21*2060 Appropriation). Funds pay and allowances of Army National Guard personnel. Includes training and other mission-related costs. See DFAS-IN Manual 37-100-XX for further details.
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VIII -
EXAMPLES:
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1. SUBJECT: Total Army School System (TASS). a. TASS is the Army’s vision of fully accredited and integrated AC/USAR/ARNG schools that provide standardized individual training and education for America’s Army. b. Prior to TASS, CONUS Armies controlled the USAR schools through the U.S. Army Reserve Commands (ARCOM). The USAR schools had in excess of 13,000 paid drill spaces to provide adequate numbers of school staff and instructors to conduct needed training; however, they had no documented equipment with which to conduct training. The NG had available equipment for training, but generally did not have the assigned instructors. Consequently, the USAR would borrow equipment from the NG and the NG would borrow instructors from the USAR. The support was usually provided from one component to another without cost. c. The downsizing of the Army has seen a major reduction in TDA personnel in both the USAR and ARNG. The reductions in USAR school TDAs have severely curtailed USAR capacity to provide instructor support to the ARNG. At the same time, reduced funding has effectively ended the capacity of one component to provide personnel or equipment support to the other without reimbursement. FUNDING ISSUES/RESOLUTIONS: a. Historically, the NG and USAR provided instructors, facilities and equipment at no charge in most situations. The new requirements under TASS surfaced the USAR and NG problems of not having sufficient resource levels (current or future) to accomplish the TASS mission. b. Current FY 96 funding levels are not sufficient to support new missions unless reimbursement is provided for the additional support now required. Funding issues can be resolved through receipt of funding from ABO, NGB or OCAR to the respective supplier, or reimbursement between the applicable appropriations.
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c. Out-year funding issues (FY 98 and beyond) can be resolved in budget and POM development cycles. d. Shortfalls in the P&A appropriations (MPA/RPA/NGPA) can be resolved through reimbursements between the P&A appropriations. O&M shortfalls can be resolved through reimbursements between the O&M appropriations (OMA, OMAR, OMNG). As stated previously, reimbursement transactions for P&A funds can only be initiated by the fund managers. MPA is centrally managed by ABO, and only they can initiate MPA reimbursement transactions. Other P&A funds are a combination of funds that are centrally managed and those that are not; therefore, levels of authority to initiate reimbursement transactions may vary. It is very important to remember that reimbursement transactions can be made only by those who have the authority to do so. e. Current FY 96 TASS Pay and Allowance appropriation shortfalls can be resolved by the component receiving additional funds from ABO, OCAR or NGB, or by a request to the Secretary of Defense to transfer an amount from one to the other within the Secretary of Defense’s Congressionally approved total threshold level of $2.4 Billion. f. For RPA, Funded Reimbursement Authority (FRA) is available as an option. If USAR personnel support requested cannot be resourced due to RPA shortfall, a FRA can be negotiated between receiver and OCAR. If approved, then RPA can be reimbursed for support requested. g. Use of FRA is also possible for NGPA. If ARNG personnel support requested cannot be resourced due to NGPA shortfall, a FRA can be negotiated between the receiver and OCNGB. If approved by OSD, then NGPA can be reimbursed for support requested. UNRESOLVED: No unresolved issues.
2. SUBJECT: Shop Smart
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a. Shop Smart is a Reserve Component Coordination Council initiative which transfers Active Army installation base support dollars to Reserve Component customers and permits them to select support suppliers of their choice, rather than being constrained to only a designated installation. b. Shop Smart was approved by the Vice Chief of Staff, Army, for implementation in FY 97, and earlier implementation was encouraged. c. The FORSCOM Chief of Staff approved implementation for the second half of FY 96 at the 65th ARCOM and three Regional Support Commands (RSC) - the 94th, 96th and 124th. d. The Army National Guard has developed a Unit Cost Analysis System (UCAS), (a national level cost data base), and a Provider and Customer Cost Estimator (PACCE), which is a PC-based computer model that extracts costs from the UCAS and generates automated Inter-Service Support Agreements (ISAs), to assist the 54 States, Territories, and the District of Columbia to serve as “Fort States” in their role of being suppliers and receivers of services. FUNDING ISSUES/RESOLUTIONS: a. Implementation procedures are being finalized, and meetings at the FY 96 sites were held in Feb 96. Funding will be provided to the USARC on 1 Apr 96 for the four initial sites. b. For test areas, FY 96 funding will be withdrawn from FORSCOM and issued to the USARC. The USARC will, in turn, fund the participating ARCOM and RSCs. Based on Inter-Service Support Agreements (ISSA) negotiated between the suppliers and the USARC participants, MIPRs will be issued to the DOD service suppliers for the Shop Smart functions. Any other support required from outside DOD will be funded with credit cards, fund cites, contracts, etc. c. Army-wide implementation begins in FY 97 for off-post Army Reserve customers. Funding will be transferred in the PPBES process to the USARC, who will issue funding documents to each RSC. The RSC will
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determine the best supplier of the support and negotiate an ISSA with DOD suppliers. Reimbursement for any services obtained from DOD will be provided on a MIPR. Any other support required will be funded with credit cards, fund cites, contracts, etc. UNRESOLVED: No unresolved issues.
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3. SUBJECT: Off-Post Area Support (OPAS)
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a. The OPAS concept is an Installation XXI initiative in which the U.S. Army Reserve Command (USARC) was tasked to develop a concept plan to transfer off-post area support responsibilities to the USAR by leveraging Reserve Component capabilities to perform certain functions. b. The concept plan was staffed within the FORSCOM headquarters and the initial 32 functions for consideration were reduced to 23. The 23 remaining functions for transfer are Engineering support (19 functions), credit card support for small purchases, Direct Support (DS) maintenance, supply, and physical security. FUNDING ISSUES/RESOLUTIONS: a. The USARC concept plan identified staffing levels based upon manpower standards/requirements and funding levels based upon costing standards. FORSCOM installation funding and staffing levels are based upon affordability, not standards. b. A significant amount of the support provided involves TRADOC installations which have not yet been included in the resource requirement determination. c. Installation input into the determination of candidate support areas and associated resources has been requested and is scheduled to be submitted to HQ FORSCOM no later than 15 Mar 96. This action will identify those areas and resources which the installations consider a prudent business decision to transfer to the USARC. Installation participation in the process should ensure command-wide support and transfers will be accomplished only where mutually beneficial. d. Upon identification of appropriate support categories and resources, funding and staffing would be withdrawn from the installations and provided to the USARC. Concurrently, the off-post support mission(s) would transfer to the USARC. Appropriate documentation would be made to transfer OMA funding to the OMAR appropriation through the PPBES process.
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UNRESOLVED: Awaiting installation input to determine issues for resolution, if any.
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4. SUBJECT: Chairman, Joint Chiefs of Staff (JCS) Exercises.
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a. The CJCS Exercise Program, approved by the CJCS, consists of exercises and training activities planned and scheduled annually for a 5-year period. The use of the acronym “CJCS” is the formal term used in regulations and other publications for this program; however, the acronym “JCS” is the term that is commonly used. Therefore, “JCS” is the term that will be used in the remainder of this document. b. The prescribing Army regulation for JCS Exercises is AR 350-28, Army Exercises. FORSCOM Regulation 350-5, Joint Training Exercises, also provides policy and guidance for FORSCOM units’ participation in JCS and other exercises. FUNDING ISSUES/RESOLUTIONS: a. FORSCOM appoints a FORSCOM action agent and an executive agent (a FORSCOM installation, organization or activity) for each exercise in which it participates. b. OMA funds for JCS Exercises are received by FORSCOM from ABO on a FAD. FORSCOM sends the executive agent funding via FAD. The executive agent, in turn, sends OMA funding to exercise participants (Army, USAR, and Army National Guard) using a Military Interdepartmental Purchase Request (MIPR). These funds pay for incremental costs associated with the exercise. c. The JCS provides Port Handling/Inland Transportation (PH/IT) funding through ABO to FORSCOM. The PH funds pay for commercial expenses to receive and dispatch cargo at points of embarkation and ports of debarkation associated with Military Sealift Command (MSC) shipping for JCS Exercises. The IT funds pay for moving exercise participants (does not fund the use of commercial air) and cargo by commercial-for-hire firms when organic transportation is not available or cost-effective. d. For Active Component units, some costs are charged to their own OMA funds in addition to those charged to JCS Exercise OMA funds. For Reserve Component units, costs can also be incurred that are chargeable to the OMAR, RPA, OMNG, and NGPA appropriations.
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e. In general, OMA JCS funds are used to pay for incremental costs resulting from Army Component participation in JCS Exercises. They fund incremental expenses incurred in connection with the planning, conduct, and evaluation of JCS Exercises over and above normal operating costs of the units involved. For Active Component units, the basic factors affecting the decision as to who provides funding are based on whether or not the costs incurred are incremental costs (costs resulting from participation in the exercise). JCS Exercise funds are used to reimburse basically the same incremental costs of participating Reserve Component units. Accordingly, for Reserve Component units these same factors still apply; however, there are additional rules, as discussed in paragraph 4g below. f. Detailed guidance concerning costs funded and not funded with JCS funds is provided in AR 350-28. g. The policies provided above apply to the Army components in general; however, there are additional rules that apply to the Reserve Components. The additional rules are as follows: (1) If the unit is in Annual Training (AT) status, Reserve Component funds pay part of the cost. The Regional Support Commands (RSC) fund normal AT Costs (14 days) of pay and allowances (RPA) and travel. The amount paid equals the amount required to move the unit to and from its AT site. If the unit is not a normal AT site, the amount paid equals the cost of moving the unit to and from its mobilization station. The JCS PH/IT funds pay the remaining cost of moving the unit to and from the exercise area port of embarkation (POE), aerial port of embarkation (APOE), point of debarkation (POD), and aerial port of departure (APOD). (2) If the unit is in an other than AT status, JCS transportation funds and PH/IT funds pay all costs of moving the personnel and equipment. (3) If JCS funds are not available, Reserve Component funds (if available) will pay for all the costs. (4) Reserve Component units participating in a JCS Exercise must be JCS troop-listed in order for JCS funds to be used. In some instances Reserve Component units participate in exercises even though they are not
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troop-listed. The OMAR/OMNG funds pay for in-country support costs for non-JCS troop-listed USAR/ARNG personnel. The JCS funds normally pay for in-country support costs for JCS troop-listed personnel. (5) When Reserve Components are conducting Overseas Deployment Training (ODT), the National Guard and USAR fund all non-pay and allowance in-country costs directly related to ODT from their respective O&M Appropriations. The NGB provides the OMNG funding through direct allocation to the OCONUS command, to pay for the incountry support costs. The OCAR provides the funding for OMAR incountry support costs directly to the Army Component for the supported unified specified command. h. On the next page is a chart that shows how JCS and RC funds are used or not used when ODT exercises are conducted in conjunction with JCS and non-JCS Exercises. More information concerning ODT is provided in the following section on Reserve Component ODT. UNRESOLVED: No unresolved issues.
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FUNDING RC ODT EXERCISES (JCS/NON-JCS EXERCISES)
IS UNIT TROOP LISTED?
RC (USAR/ARNG) FUNDS (RPA/NGPA):
YES
IS IT A JCS EXERCISE?
YES
IS UNIT IN AT STATUS?
• TRANSPORTATION (PERS ONLY) -- HOME STATION TO APOE -- APOE TO HOME STATION
YES
• PAY & ALLOWANCES
JCS FUNDS (OMA & PH/IT): NO NO
RC (USAR/ ARNG) FUNDS (RPA/NGPA):
• TRANSPORTATION (PERS & EQUIP) -- HOME STATION TO APOE -- APOE TO EXERCISE • INCREMENTAL COSTS EXAMPLES ARE: -- PRE-DEPLOYMENT SITE SURVEYS (PDSS) -- EQUIP REFURBISHMENT COSTS -- NON-TOE EQUIPMENT NEEDS • PLANNING CONFERENCE PER DIEM
• TRANSPORTATION (PERS ONLY) • PAY AND ALLOWANCES
NO
JCS FUNDS (OMA & PH/IT): RC (USAR/ ARNG) FUNDS (OMAR/ OMARNG): \1 (AND)
• EQUIP TRANSPORTATION • IN-COUNTRY SUPPORT COSTS
(AND)
• TRANSPORTATION (PERS & EQUIP) -- HOME STATION TO EXERCISE -- EXERCISE TO HOME STATION • IN-COUNTRY SUPPORT COSTS
(AND)
\1 NGB/USAR PROVIDE $$ TO HOST TO PAY COSTS
RC (USAR/ARNG) FUNDS (RPA/NGPA):
• PAY & ALLOWANCES
Note: Although not shown on the above diagram, if the purpose of the ODT is primarily for the support of the Active Component or to accomplish Active Component missions, then OMA funds the subsistence, transportation to and from OCONUS duty locations, and in-country costs. This is discussed in paragraph c on the following page.
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5. SUBJECT: Overseas Deployment Training (ODT) of Reserve Component Units. a. Reserve Component ODT is the training of Reserve Component units with commands, host nation, CONUS based Corps and Third U.S. Army, and such training is Outside the Continental United States (OCONUS), and U.S. territories and possessions. b. The ODT includes training performed in conjunction with JCS Exercises. The prescribing Army regulation for ODT Exercises is AR 350-9, Overseas Deployment Training. FUNDING ISSUES/RESOLUTIONS: a. ARNG. (1) If the unit is not a JCS troop-listed unit participating in a JCS Exercise, the ARNG funds the Operation and Maintenance in-country costs directly related to ODT from the OMNG appropriation. The OMNG funds are provided by the NGB through direct allocation to the OCONUS command. (2) Pay and allowances are funded with NGPA funds allocated to the states concerned, whether or not the unit is a JCS troop-listed unit. b. USAR. (1) If the unit is not a JCS troop-listed unit participating in a JCS Exercise, Operation and Maintenance in-country costs are funded by the OMAR appropriation. (2) Pay and allowances are funded with RPA funds whether or not the unit is a JCS troop-listed unit. RPA funds also pay for transportation costs from the CONUS home station to the OCONUS training location. c. The purpose of the ODT described in the above sections is considered for training of Reserve Component personnel only. If the purpose of the ODT is primarily for the support of the Active Component or to accomplish Active Component missions, then OMA funds the subsistence, transportation to and from OCONUS duty locations, and
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in-country costs, not the Reserve Component appropriations. d. Only general guidance is contained in these paragraphs. For all components, reference should be made to AR 350-9, AR 350-28, FORSCOM Regulation 350-5, and other guidance. UNRESOLVED: No unresolved issues.
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APPENDIX A: REFERENCES:
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1. DOD Instruction 4000.19, Inter-Service & Intra-Governmental Support, 9 Aug 95. 2. Draft, DOD Financial Management Regulation, Volume 11A, Reimbursable Operations, Policy and Procedures, January 1996. 3. DFAS-IN Regulation 37-1, Finance and Accounting Policy Implementation, 18 Sep 95. 4. DFAS-IN Manual 37-100-XX, The Army Management Structure. 5. Army Regulation 5-9, Inter-Service Support Installation Area Coordination, 1 Mar 84. 6. Army Regulation 350-28, Army Exercises, 12 Apr 91. 7. Army Regulation 350-9, Overseas Deployment Training, 20 Oct 88. 8. Memorandum, HQDA, Subject: Army Reimbursable Policy, 19 May 95. 9. DA Pamphlet 710-2-1, Using Unit Supply System - Manual Procedures, 28 Feb 94. 10. FORSCOM Supplement to AR 5-9, Inter-service Support Installation Area Coordination, 4 Jun 93. 11. FORSCOM/National Guard Bureau Regulation 350-2, Reserve Component Training in America’s Army, 1 Mar 95. 12. FORSCOM Regulation 350-4, AC/RC Training Association Program, Chapter 4, Funding, 1 Jan 95. 13. FORSCOM Regulation 350-5, Joint Training Exercises, 1 May 90. 14. USARC Regulation 37-1, USAR Financial Management and USAR Support, 1 Oct 93.
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15. Office of the Assistant Secretary of the Army (Financial Management & Comptroller) Reprograming Directive. 16. Memorandum, Department of the Army, Office of the General Counsel, Subject: Use of Operation and Maintenance, Army (OMA) Appropriation in Support of Overseas Deployment Training (ODT), 4 Jan 94. 17. Memorandum, Department of the Army, Office of the General Counsel, Subject: Reimbursements Among the Three Army Military Personnel Appropriations, 29 Apr 96.
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APPENDIX B: DEFINITIONS
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CROSS-COMPONENT FUNDING - Cross-Component funding occurs when one component requests support from another component, and the component providing the support has not programmed or budgeted for that support. Until funds can be reprogrammed to the service supplier in the out-years, the requesting component must provide funding for that support. SHOP SMART - Shop Smart is a Reserve Component Coordination Council initiative which transfers Active Army installation base support dollars to Reserve Component customers and permits them to select support suppliers of their choice rather than continuing to rely upon the installations. In Jun 95, the Vice Chief of Staff of the Army approved Shop Smart for implementation in FY 97 and encouraged earlier implementation. On 19 Jan 96, the FORSCOM Chief of Staff approved implementation for the second half of FY 96 at three Regional Support Commands (94th, 96th, and 124th) and the 65th ARCOM. Each installation has developed pricing guidance for all Shop Smart categories (Visual Information Services, Contracting, Environmental Compliance, ID Card Support, Physical Security Inspections, Safety Services, and Supply). Implementation procedures were finalized, meetings held at the sites in Feb 96 and funding was provided to USARC on 1 Apr 96 for the four initial sites. TRI-COMPONENT FUNDING - When multiple appropriations (OMA, OMAR, and OMNG) fund a program that was previously funded by only one appropriation. An example is the funding of the CONUSA Headquarters, which is now Tri-Component funded, but was previously funded with OMAR. OFF-POST AREA SUPPORT - This was a FORSCOM initiative to move the responsibility for off-post customer support from Active Component to Reserve Component. USARC was tasked to come up with proposal to transfer the support to the Reserve Component; details of this program remain under study. JOINT CHIEFS OF STAFF (JCS) EXERCISE PROGRAM - The JCS Exercise Program is approved by the CJCS. It consists of exercises and training activities planned and scheduled annually for a 5-year period. A program exercise may be sponsored by the Joint Staff, a combatant command, a Service, or a defense agency. Exercises may take the form mainly as
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Command Post Exercises (CPX), Field Training Exercises (FTX), or Command Field Exercises (CFX). Training activities include simulations and war games. The prescribing Army regulation for JCS Exercises is AR 350-28, Army Exercises. FORSCOM Regulation 350-5, Joint Training Exercises, also provides policy and guidance for FORSCOM units’ participation in JCS and other exercises. OVERSEAS DEPLOYMENT TRAINING (ODT) - The term Overseas Deployment Training refers to OCONUS training deployments by Reserve Component units. The training is conducted with commands, host nations, CONUS-based corps, and Third U.S. Army Outside the Continental United States (OCONUS) and U.S. territories and possessions. The prescribing regulation is AR 350-9, Overseas Deployment Training. The ODT excludes exchanges of small units or personnel between the U.S. Army and armies of allied and friendly nations, temporary cross-border movement of land forces between CONUS and Canada, and other programs and training specifically governed by ARs other than AR 350-9. Army Component participation in ODT exercises directed, coordinated, or approved by the JCS are governed IAW AR 350-28, Army Exercises, in addition to AR 350-9. TOTAL ARMY SCHOOL SYSTEM (TASS) - TASS is the Army's vision of fully accredited and integrated AC/USAR/ARNG schools that provide standardized individual training and education for America's Army. Under TASS, each RC school will be functionally aligned with a proponent service school. When fully implemented, the goal of TASS is for proponentcertified instructors in proponent-accredited schools to provide standardized, quality instruction, using quality Total Army School System courseware. THE “ECONOMY ACT,” 31 USC 1535, AGENCY AGREEMENTS. The 31 USC 1535 states the following: “(a) The head of an agency or major organizational unit within an agency may
place an order with a major organizational unit within the same agency or another agency for goods and services if (1) amounts are available; (2) the head of the ordering agency or unit decides the order is in the best interest of the United States Government;
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(3) the agency or unit to fill the order is able to provide the ordered goods or services; and (4) the head of the agency decides ordered goods or services cannot be provided as conveniently or cheaply by a commercial enterprise. (b) Notwithstanding subsection (a)(3) of this section, the Secretary of Defense, the Secretary of a military department of the Department of Defense, the Secretary of Transportation in carrying out duties and powers related to aviation and the Coast Guard, the Secretary of the Treasury, the Administrator of General Services, and the Administrator of the Maritime Administration may place orders under this section for goods and services that any agency or unit filling the order may be able to provide or procure by contract. (c) Payment shall be made promptly by check on the written request of the agency or unit filling the order. Payment may be made in advance or on estimated or actual cost as determined by the agency or unit filling the order. A bill submitted or a request for payment is not subject to audit or verification in advance of payment. Proper adjustment of amounts paid in advance shall be made as agreed to by the heads of the agencies or units on the basis of actual cost of goods or services provided. (d) An order placed or agreement made under this section obligates an appropriation of the ordering agency or unit. The amount obligated is deobligated to the extent that the agency or unit filling the order has not incurred obligations, before the end of the period of availability of the appropriation, in(1) providing goods or services; or (2) making an authorized contract with another person to provide the requested goods or services. (e) This section does not(1) authorize orders to be placed for convict labor; or (2) affect other laws about working funds.”
Per the Department of the Army Office of the General Counsel memorandum referenced in paragraph 17 of Appendix A, “This memorandum
responds to your request for an opinion on the legality of allowing the three Army military personnel appropriations to reimburse one another when cross-component services are provided. For example, you asked how to pay for USAR members who provide services to the National Guard to fulfill a National Guard need. The “Economy Act,” 31 USC 1535, allows major organizational units within the same agency to place
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orders with, and pay one another for, services provided each other in accordance with the statute. We are unaware of any additional statute that prohibits the National Guard from paying the USAR for personnel services provided by the USAR from its personnel appropriation....”
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